Corrective Action Plans

Finding Number: 2024-007 Finding Title: Reporting Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Colleen Robeck, Finance Director Corrective Action Planned: McLeod County recognizes the importance of internal controls over federal awards to be in compliance with federal statutes, regulations, and terms and conditions of the federal award. McLeod County has corrected the misstatements of contracts payments that should have been originally charged to the COVID-19 Coronavirus State and Local Fiscal Recovery Funds expenditures. Anticipated Completion Date: This issue will be resolved by December 31, 2025.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Pass-through: County of Sacramento Award Year: FY 2024 Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.Sl0(b) - Schedule of Expenditures of Federal Awards Grant Award Number: DHA-PRTS-NM-07-25-Al Finding Summary: During the audit procedures performed over the SEFA and expenditures reported for the Temporary Assistance for Needy Families program, we noted the Organization overstated expenditures by $138,217. The December 31, 2024 SEFA was corrected for this reporting error. Repeat Finding from Prior Years: No. Management's Response: The Organization acknowledges the reporting error identified during the audit procedures related to the SEFA. Upon notification of the discrepancy, the Organization promptly corrected the SEFA to reflect accurate expenditures. To prevent future occurrences, the Organization will strengthen internal review procedures for SEFA preparation, including cross-verification of reported expenditures with general ledger details. Name of Responsible Person: Projected Implementation Date: Bryan Wagner, CFO 09-05-2025

SHN will ensure that all Federal Awards are carefully reviewed to confirm that the Federal Assistance Listing Number is accurately stated, the pass-through entity identifying numbers are correct, and are included in the correct Cluster.

Isler recommended LCOG implement procedures to:  Formally document the determination of whether entities receiving federal funds are subrecipients or contractors prior to entering into agreements and preparing the SEFA, using the criteria in 2 CFR 200.331.  Develop and implement a risk-based monitoring plan for all identified subrecipients, ensuring that required monitoring activities (including review of reports and Single Audits, where applicable) are performed and documented throughout the period of performance.  Ensure the SEFA accurately reflects subrecipient relationships and amounts passed through.  This monitoring plan has already been implemented.

Management acknowledges the finding and concurs with the auditor’s recommendation. The challenges identified were primarily the result of a major transition in accounting personnel during 2024. In August 2024, CRMSDC’s long-serving in-house accountant of nine years resigned unexpectedly, leaving limited time for an adequate transfer of knowledge and responsibilities. To preserve continuity in financial operations, CRMSDC immediately engaged outsourced accounting support. Looking ahead, CRMSDC will undertake a full review of its financial management structure and secure a highly qualified accountant or financial professional with specialized expertise in nonprofit accounting and federal grant compliance. Combined with strengthened procedures and enhanced supervisory oversight, these actions will build organizational capacity, reinforce internal controls, and ensure accurate and timely financial reporting. Name of the contact person responsible for corrective action: Sharon R. Pinder, President, 301.593.5861 Planned completion date for corrective action plan: Assessment and Correction – 4th Quarter 2025

Views of responsible officials and planned corrective actions Quivira Coalition has made efforts to fully comply with federal allowable cost rules, including implementing a compliant time and expense system, implementing a compliant accounting system, consulting with federal program officers, and requesting budget revisions when necessary. However, management agrees that despite its efforts it did not correctly attribute allowable non-personnel and personnel costs to the grants, resulting in errors on the Schedule of Expenditures of Federal Awards (SEFA). Management has analyzed the errors and determined the root causes. Management agrees that the root cause of finding 2024-001 is the discrepancy between the accounting system and time and expenses software system, and that this is material to grant management. After reconciling these discrepancies, as discussed below, management believes the estimated amount for Beginning Farmer and Rancher Development Program; Award: BFRDP - 2023 - 49400 - 40894 (AL 10.311) to be $7,002 and for Partnerships for Climate-Smart Commodities; Award: USDA/NR243A750004G005 (AL 10.937) to be $10,169. Non-Personnel Costs Discrepancies in non-personnel costs were primarily caused by human errors. Management conducted a post-audit reconciliation between the expense tracking system (Harvest) and the general ledger (QuickBooks) which identified the 2024 discrepancies, and Quivira has corrected them. Personnel Costs Discrepancies in labor costs were due to three factors: 1) Quivira Coalition personnel are paid for holidays and paid time off (PTO) and therefore personnel costs include PTO and holiday costs in QuickBooks. However, Quivira’s timekeeping system (Harvest) does not burden federal award personnel costs with PTO and holiday costs making it difficult to reconcile. 2) To allocate personnel costs to a grant, Quivira used the Harvest system. This system calculates a fixed cost rate for each person based on their total annual compensation and expected work capacity and then multiplies this fixed cost rate by the number of hours worked on each grant (as recorded in the Harvest System). However, using fixed cost rates can result in misallocation in situations where personnel work over capacity (e.g. overtime) or under capacity. The appropriate cost allocation approach for salaried employees is to allocate actual personnel costs for a task based on the percentage of total hours worked. 3) Quivira calculated personnel fringe costs based on an estimated hourly fringe rate rather than identifying and allocating actual fringe expenses from QuickBooks. To correct for this material weakness, Quivira Coalition will: Action Step Detail Date Responsible Party Develop a new, compliant method to allocate personnel costs for federal billing and reporting. Stop using the timekeeping system (Harvest) for allocation. The new method must properly reflect actual paid salaries, paid fringe, and actual time spent. 12/31/2025 Accounting Firm Update reporting process to reconcile all costs reported on the SF-425 to the general ledger (instead of the timekeeping system) using the new federal grants billing process. Keep detailed records of the reconciliation. 12/31/2025 Accounting Firm Implement a monthly reconciliation process between the time and expense system (Harvest) and the QuickBooks general ledger to reconcile all non-personnel expenses. 1/31/2026 Operations Director Document the grant management process, including new reporting processes, required reconciliations, monitoring policies, and allowable cost management to ensure consistency across the organization. 2/28/2026 Operations Director Update policies and procedures to require that expenses reported on the SEFA form come directly from the accounting system to ensure this continues. 1/31/2026 Operations Director Update policies and procedures to require an annual reconciliation between the SF-425 and SEFA reports to ensure this continues. This occurs before submitting the SEFA report. 1/31/2026 Operations Director Reconcile all grant programs active in 2024 and 2025 using updated processes and resolve any discrepancies with federal reports or billing. 2/28/2026 Initial Review - Operations Director & Grants Manager Secondary Review & Corrections (if needed) - Accounting Firm Develop a plan to ensure regular and sufficient training on Uniform Guidance tracking regulatory changes, and how to implement changes. Update policies and procedures. 11/30/2025 Operations Director & Executive Director Update policies and procedures to require an additional level of review and approval for SF-425 and SEFA reports and reconciliations for accuracy and completeness before they are submitted. 12/31/2025 Operations Director with final approval from the Executive Director

The Organization acknowledges that one Federal grant was omitted from the original SEFA submitted for audit, requiring a restatement. To correct this issue, management will implement a reconciliation process that compares all grant revenue accounts and funding agreements to the draft SEFA prior to submission. The Organization will also designate a member of the finance team to perform an independent review of the SEFA for completeness and accuracy. These procedures will help ensure that all Federal awards are properly identified, included, and reported in the SEFA in future reporting periods.

The Organization will review all of its grant agreements to properly ensure that all federal awards have been identified and included in the SEFA.

Corrective Action Plan: The County has agreed to strengthen internal controls through regular reconciliations between project managers and the Clerk’s office to ensure timely reporting, submission for reimbursement and inclusion on the financial statements. Responsible Party: Alpena County Treasurer and Alpena County Administrator Date of Planned Corrective Action: July 1, 2025 Management Assessment: We concur with the audit assessment regarding this matter.

The Code of Federal Regulations (CFR) section 200.510 (b) states that the audit, the data collection form, and the reporting package must be submitted within 30 calendar days after the auditee receives the auditor's report(s) or nine months after the end of the audit period (whichever is earlier) to the Federal Audit Clearinghouse (FAC). Corrective: Policies, procedures, and internal controls have been implemented to ensure that all required federal reporting is submitted timely to the Federal Audit Clearinghouse (FAC), in accordance with the Code of Federal Regulations (CFR), Title 2, Section 200.510(b).

Finding summary: an internal control deficiency affecting the accuracy of the Schedule of Expenditures of Federal Awards (SEFA) Responsible department: Finance and PPACG Contact person: Finance Corrective action plan: As of 2025 SEFA internally will be prepared by Grant coordinator and review by Finance. Envida will ensure that all appropriate ALNs and Federal identifications and amounts are included on the contracts. Envida will implement a process for all appropriate department directors, including CEO to sign off on each grant received. Timeline for completion: Dec 31 2025 Monitoring plan: Monthly Review with Grant coordinator Anticipated outcome: SEFA will reflect accurate federal expenditures.

Feonix leadership will prepare and submit a corrective action plan addressing the 2024 material weakness. The plan will include specific steps to ensure complete and accurate reporting of all federal grant revenue. Management will strengthen review procedures so that all federal funding streams are properly identified and reconciled to the general ledger before preparation of the SEFA. A crosswalk between the general ledger and the SEFA will be developed to verify that all federal grant activity is captured.

Executive Director will work with all program areas to ensure that all federal awards and subawards are identified as such to ensure we track properly • ED will ensure we have written documentation for all federal pass-through funding with correct ALN numbers and communicate the information to the third party accountants • ED will verify the federal nature of all awards and stay current on SEFA and Uniform Guidance

Finding 2024-001 – ReportingAssistance Listing No.: 93.391, COVID-19 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crisis Assistance Listing No.: 93.323, COVID-19 Epidemiology and Laboratory Capacity for InfectiousDiseasesManagement will distribute the updated SEFA reporting policy and procedure, outlining the required reporting requirements and timelines. A SEFA preparation checklist will be implemented to ensure that all submissions are accurate and complete. At the end of the year, Finance and Grants Management will collaborate to review all grant activities to ensure proper inclusion in the SEFA.Responsible Official: Annaliza Villamin, System Director of Accounting, Endeavor Health

Finding 2024-007 SEFA Reporting Issue: We lacked consistent grant-level financial reporting, which made preparation of the required Schedule of Expenditures of Federal Awards {SEFA) difficult and time-consuming. • What's been done: We have improved our accounting systems and can now produce regular internal financial reports by grant. All grant managers are given a monthly transaction listing for their grants to ensure transactions are posted to the correct grant. They are also given monthly financial statements for each grant to reconcile with their records. • Next steps: Financial reporting will be done on a timely basis, ideally no more than 5 days after the month closing so grant managers can reconcile their records. • Timeline: By early October, we hope to implement the monthly closing no more than 5 days after the month end. • Responsible party: Finance manager with oversight by President

MATERIAL WEAKNESS Preparation of Schedule of Expenditures of Federal Awards Recommendation: We recommend the School implement internal controls over SEFA including a reconciliation and review process before submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action Planned/Taken : Management agrees with the finding and has created and filled the position of Manager of Grants Management. This staff member will be responsible for the oversight and management of all grants, including the SEFA. Additionally, the School has contracted with an outside firm that specializes in State Board of Accounts compliance, as well as Federal Award Compliance in line with Uniform Guidance. The firm will assist in the development of the required Internal Controls and Processes, with an estimated completion date is December 31, 2025.

Corrective Action Plan (Unaudited): The corrective actions described under Finding 2024-003 will directly address this compliance issue. Key measures include: 1) Adoption of centralized grant management policies and procedures by the end of 2025. 2) Quarterly reconciliations and independent review of SEFA reporting. 3) Annual training for Finance and department grant managers on SEFA compliance. 4) Continued use of the grant management team to enhance communication and oversight. Contact Person: Jamie Robichaud, Economy Director Anticipated Completion Date: January 1, 2026

April 30, 2025 To: Clausell & Associates, P.C. From: Camille Vickers, Executive Director of West Central Georgia Community Action Council, Inc. Below is the Council’s corrective action plan as it relates to the findings for the fiscal year ending September 30, 2024, Single Audit Act audit. Comment #2024-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED GENERAL (Repeat) Views of Responsible Officials and Planned Corrective Actions: We concur with this finding – Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Council’s financial funding sources, the Council will provide additional training to support the new fiscal officer. The fiscal officer will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. All enhancements will be implemented by July 31, 2025. Concerning the preparation of external reports required by various funding sources, the Council will ensure adequate training is provided to improve the skills and knowledge of key personnel. Policies and procedures will also be revised to support external reporting. Implementation Date: The plan correction date will be completed no later than July 31, 2025. Responsible Person: Camille Vickers, Executive Director, will be responsible for the corrective action. Comment #2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED LIHEAP FALN 93.568 (Questioned Costs – Undetermined) Views of Responsible Officials and Planned Corrective Actions: We concur with this finding – Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Council’s financial funding sources, the Council will provide additional training to support the new fiscal officer. The fiscal officer will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. All enhancements will be implemented by July 31, 2025. Concerning the preparation of external reports required by various funding sources, the Council will ensure adequate training is provided to improve the skills and knowledge of key personnel. Policies and procedures will also be revised to support external reporting. Implementation Date: The plan correction date will be completed no later than July 31, 2025. Responsible Person: Camille Vickers, Executive Director, will be responsible for the corrective action.

In September 2025, Management has implemented the following corrective action item to eliminate the 2024-001 finding: 1. Management has redesigned our schedule of federal awards template to align with the format presented in the Single Audit report, thus eliminating reliance on summation formulas. 2. Management has implemented an additional review of the draft Single Audit report to be performed by the Controller. This is followed by the final review from the CFO before the report submission. Staff have reviewed the applicable Uniform Guidance (2 CFR 200.510b) to ensure full comprehension of reporting requirements. All corrective action items have been implemented and followed for the preparation of the schedule of federal expenditures. Contact Person Responsible for Corrective Action: Blaine Hoovis, Chief Financial Officer Email: BHoovis@ifaw.org Phone: 1 508 744 2134

2024-004 Improve Internal Controls Over the Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Management Response and Corrective Action Plan (DPW): Management concurs with the finding. The City / DPW will implement enhanced reconciliation procedures to ensure all SF-425 reports agree to the general ledger and SEFA, with independent review prior to submission. Management Response and Corrective Action Plan (EPD): Management concurs with the finding. The City / EPD will implement enhanced reconciliation procedures to ensure all SF-425 reports agree to the general ledger and SEFA, with independent review prior to submission. Management Response and Corrective Action Plan (Planning): Management concurs with the finding. The City / Planning Department will implement enhanced reconciliation procedures to ensure all SF-425 reports agree to the general ledger and SEFA, with independent review prior to submission. Planned Implementation Date: 12/17/2025 Person Responsible for Corrective Action: Julianne Pelletier

Views of Responsible Officials: Management concurs with the auditor’s findings related to Federal award compliance and questioned costs. Several internal transitions contributed to the control gaps and compliance lapses identified during the audit period, including:  The implementation of a new chart of accounts and a new instance of the Sage Intacct accounting system, which impacted reporting structures and account mapping for Federal programs.  A transition in finance leadership, which affected oversight of Federal grant compliance and reporting.  The lack of timely replacement for a key vacant finance position, which limited staff capacity during critical reporting periods. These factors collectively contributed to the challenges experienced in adhering to certain requirements under the Uniform Guidance, including the accurate preparation of the Schedule of Expenditures of Federal Awards (SEFA) and the documentation of allowable costs. To address the findings and prevent recurrence, management has taken or is taking the following steps:  Staff training on SEFA preparation and Uniform Guidance requirements will be conducted to ensure a full understanding of Federal compliance obligations. Will ask GRF what recommendations they have for trainings by August 2025.  Verify chart of accounts mapping for Federal grants has been finalized and validated within the new Intacct system to support more accurate tracking of expenditures. – Complete by September 2025.  The utilization of the C-STAAR system will support a more structured and consistent internal grant management process.  Finance will also evaluate the grants management module within the accounting system to determine feasibility for integration and ease of syncing with SEFA reporting requirements.  A calendar of Federal reporting deadlines will be developed to strengthen compliance monitoring and accountability. – By October 2025. Management is committed to improving its internal controls and ensuring compliance with all applicable Federal requirements moving forward.

Corrective action plan: The Finance Department will begin close out work on the year under audit as soon as the year ends, so that all accounts including expenditures will be accurately adjusted before the SEFA is prepared. Finance will verify all Assistance Listing Numbers on the SEFA. Once the SEFA is prepared, it will be independently reviewed by a contracted CPA before submitting the SEFA to the auditor. Personnel responsible for corrective action: Lisa Donham (Finance Manager) and contracted CPA consultant. Estimated corrective action completion date: March 31, 2026

Finding 2024-003 – Preparation of Schedule of Expenditures of Federal Awards (SEFA) (Material Weakness) (Repeat Finding) Corrective Action Plan Strengthening Internal Controls • Implement a formal SEFA preparation checklist aligned with the Uniform Guidance. • Require dual-level review (Finance Manager and Executive Director) of all SEFA schedules before submission to external auditors. • Establish reconciliation procedures that tie SEFA expenditures to the general ledger, grant agreements, and drawdown records. Year-End Closing Procedures • Revise year-end close calendar to include specific SEFA preparation deadlines and review steps. • Require supporting documentation (trial balance reports, grant reconciliations, and expenditure detail by funding source) to be retained and cross-referenced to the SEFA. Training • Provide targeted training to finance and grants staff on SEFA preparation, Uniform Guidance requirements, and OMB Compliance Supplement updates. • Require annual refresher training for staff responsible for grant accounting and reporting. Responsible Parties • Finance Director (Primary) • Executive Director (Oversight and Resources) Anticipated Completion Date Full implementation by June 30, 2025 (in time for fiscal year 2024-2025 reporting cycle).

Finding 2024-004 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.041 Impact Aid Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Sched-ule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the to-tal Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipi-ents. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements.   Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger, and contained inaccuracies, including: • Overclaimed revenues for Title I • Inability to provide sufficient documentation of Impact Aid revenues and specific Impact Aid program infor-mation • Incorrect reporting of state and federal revenues for National School Lunch Program. Cause: The District does not have effective internal control over the preparation of the Schedule of Expenditures of Federal Awards. The district did not reconcile the expenditures reported on the SEFA with the amounts reported on the district's general ledger. Effect or Potential Effect: Potential understatement or overstatement of expenditures could exist in the Schedule of Expenditures of Federal Awards and not be detected and corrected. Because the SEFA was completed incorrectly, and not reconciled to the general ledger, the financial statements were materially misstated prior to the auditor's adjust-ments. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting re-sulted in the following: SEFA was originally presented for auditors with incorrect information, and not reconciled to the general ledger Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or cor-rect errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and re-view the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identi-fied and reported accurately on future SEFAs. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager Section IV—Summary Schedule of Prior Audit Findings There were no findings for the fiscal year ended June 30, 2023.

Responsible Official’s Response and Corrective Action Planned: We have implemented procedures to ensure that the SEFA includes all federal expenditures incurred during the reporting period, regardless of whether reimbursement has been requested. Reconciliation of the SEFA amounts are completed monthly. Management will also offer and require training to all personnel responsible on the Uniform Guidance requirements for SEFA reporting.